GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

Introduction

Halo Support ("We") are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions

Data controller:

A controller determines the purposes and means of processing personal data.

Data processor:

A processor is responsible for processing personal data on behalf of a controller.

Data subject:

Natural person

Categories of data: Personal data and special categories of personal data

Personal data:

The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data:

The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing:

Means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party:

Means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

For all data matters contact Tom Lewis on 07446975496, info@halo.support

3. The purpose(s) of processing your personal data

We use your personal data for the following purposes:

Providing ICT services to you in line with any contract you have in place with us.

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data:

Personal data:

Email address

Full Name and Title

Job Title/Position within organisation

We have obtained your personal data from your organisation at the point of commencing a working relationship with us for the purposes of supplying you with ICT services.

5. What is our legal basis for processing your personal data?

Personal data (article 6 of GDPR)

Our lawful basis for processing your general personal data:

☐ Consent of the data subject;

*include a gdpr consent form

✓ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract

ICT Support Service

☐ Processing necessary for compliance with a legal obligation

☐ Processing necessary to protect the vital interests of a data subject or another person

☐ Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

☐ Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject

More information on lawful processing can be found on the ICO website.

6. Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared only with:

Tom Lewis and Mark Haycock - Co-Founders of Halo Support

Third party companies as requested by yourself i.e. Google (If setting up Google for Education), Apple (If setting up iPads) – Any requests of this nature will require written permission from you (email format will be accepted)

7. How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary for a period of 12 months or for the duration of your ICT Support Service with us in order to provide the services purchased.

8. Providing us with your personal data

We require your personal data as it is a contractual requirement.

9. Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

The right to request a copy of the personal data which we hold about you;

The right to request that we correct any personal data if it is found to be inaccurate or out of date;

The right to request your personal data is erased where it is no longer necessary to retain such data;

The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);

The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

10. Transfer of Data Abroad

It is sometimes necessary for us to transfer data to countries outside of the EEA. Whenever we transfer data outside of the EEA we take all steps possible to ensure that the company storing the data complies with data processing practices such as the EU-US Privacy Shield Framework.

11. Automated Decision Making

WE DO NOT USE ANY FORM OF AUTOMATED DECISION MAKING IN OUR BUSINESS.

Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

12. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be notified to you by e-mail.

13. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Tom Lewis on 07446975496 info@halo.support